Just to be clear - when describing the density of the Sudbury project I was trying to answer the question: "what is the density of the buildings". I was not making any statement about the lot density or any HCA calculations.
I can not speak for the HCWG, but they are concerned I believe with the regulations because the state agencies are empowered to define what it means to comply with the law. On Mon, Oct 9, 2023 at 4:33 PM Karla Gravis <karlagra...@gmail.com> wrote: > Waterlands and septics can be taken out for "gross density" > <https://www.mass.gov/info-details/section-3a-guidelines#6.-minimum-gross-density-> > calculations per 3A guidelines, BUT publicly owned land CANNOT. > > > > The 9.9 acres in the Sudbury parcel that are owned by the town cannot be > excluded from the denominator in the density calculation. The calculation > shared by Margaret of 21 units per acre is not accurate, since it removes > publicly owned land. According to the guidelines, the Sudbury project has a > density of 274 units in 26-3.1=22.9 acres or 12 units per acre, below the > 15 units per acre needed for HCA compliance. *Any zoning approved in > Lincoln that pertains to follow the guidelines would have to be DENSER than > what is being built in Sudbury. *Rob is right - I encourage folks to take > a look at the Subdury project here > <https://sudbury.ma.us/pcd/2020/05/07/cold-brook-crossing-residential-development-planning-board-permitting-application-materials/> > . > > > > I would also point out that the RLF proposed a plan to build at a density > of 25 units per acre (slide 48 > <https://www.lincolntown.org/DocumentCenter/View/79138/2023-06-16-HCA-Public-Forum-Slide-Deck?bidId=>). > That is almost twice as dense as the project in Sudbury. > > > > The model Rob is building will help people understand the enormity of the > changes being floated. > > > > The working group has not explained why it is solely concerned with > following the guidelines, which keep changing and could continue to change > even after we vote for any hypothetical rezoning. Guidelines are not law > nor regulation. We should be more concerned with what the law states than > with attempting to follow guidelines that are merely interpretations of the > law by government agencies and are constantly changing. > > > ———————- > > > > Section 3A guidelines – 6. Minimum Gross Density > > > > a. District-wide gross density > > > > To meet the district-wide gross density requirement, the dimensional > restrictions and parking requirements for the multi-family zoning district > must allow for a gross density of 15 units per acre of land within the > district. By way of example, to meet that requirement for a 40-acre > multi-family zoning district, the zoning must allow for at least 15 > multi-family units per acre, or a total of at least 600 multi-family units. > > > > For purposes of determining compliance with Section 3A’s gross density > requirement, the EOHLC compliance model will not count in the denominator > any excluded land located within the multi-family zoning district, except > public rights-of-way, private rights-of-way, and publicly-owned land used > for recreational, civic, commercial, and other nonresidential uses. This > method of calculating minimum gross density respects the Zoning Act’s > definition of gross density—“a units-per-acre density measurement that > includes land occupied by public rights-of-way and any recreational, civic, > commercial and other nonresidential uses”—while making it unnecessary to > draw patchwork multi-family zoning districts that carve out wetlands and > other types of excluded land that are not developed or developable. > > > > c. Wetland and septic considerations relating to density > > Section 3A provides that a district of reasonable size shall have a > minimum gross density of 15 units per acre, “subject to any further > limitations imposed by section 40 of chapter 131 and title 5 of the state > environmental code established pursuant to section 13 of chapter 21A.” > This directive means that even though the zoning district must permit 15 > units per acre as of right, any multi-family housing produced within the > district is subject to, and must comply with, the state wetlands protection > act and title 5 of the state environmental code—even if such compliance > means a proposed project will be less dense than 15 units per acre. > > > >> ---------- Forwarded message --------- >> From: Margaret Olson <s...@margaretolson.com> >> Date: Mon, Oct 9, 2023 at 2:59 PM >> Subject: Re: [LincolnTalk] 15 Units per Acre - Part 2: Cold Brook >> Crossing - Sudbury/Concord on 117 >> To: Robert Ahlert <robahl...@gmail.com> >> Cc: Lincoln Talk <lincoln@lincolntalk.org> >> >> >> From the project narrative ( >> https://s3-us-west-2.amazonaws.com/cdn.sudbury.ma.us/wp-content/uploads/sites/326/2020/05/Cold-Brook-Crossing-Site-Plan-Narrative-March-11-2020.pdf?version=dd2e49a8d33cbe913460c6b7d51236c4 >> ): >> >> Of the 26 acres: >> 9.9 acres are in conservation >> 3.1 acres are part of the Sudbury Water District and will remain so >> >> That leaves 13 acres. 274 units/13 acres = 21 units per acre. >> >> >> -- >> The LincolnTalk mailing list. >> To post, send mail to Lincoln@lincolntalk.org. >> Browse the archives at >> https://pairlist9.pair.net/mailman/private/lincoln/. >> Change your subscription settings at >> https://pairlist9.pair.net/mailman/listinfo/lincoln. >> >> -- > The LincolnTalk mailing list. > To post, send mail to Lincoln@lincolntalk.org. > Browse the archives at https://pairlist9.pair.net/mailman/private/lincoln/ > . > Change your subscription settings at > https://pairlist9.pair.net/mailman/listinfo/lincoln. > >
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